Ben-Davies & Moore v. Blibaum & Assoc., 177 A.3d 681

Two tenants (Ben‑Davies and Moore) defaulted on residential leases; landlords obtained District Court money judgments that included unpaid rent plus other charges (late fees, utilities, repairs), without itemizing what portion was rent.
A debt‑collection law firm (Blibaum & Associates) collected for the landlords and applied a 10% post‑judgment interest rate in collection notices and garnishment reports.
Tenants sued the collector in federal court asserting statutory claims (including FDCPA), arguing the correct post‑judgment interest rate was 6% under Md. Code, Cts. & Jud. Proc. § 11‑107(b).
The federal district courts dismissed for lack of standing; the Fourth Circuit reinstated the cases and the parties jointly certified to the Maryland Court of Appeals the legal question whether § 11‑107(a) (10%) or § 11‑107(b) (6%) governs where a judgment includes rent plus other lease‑related expenses and does not specify amounts.
The Maryland Court of Appeals held that § 11‑107(b) (6%) applies to a money judgment "for rent of residential premises" even if the judgment also includes other lease‑related expenses and the judgment is not apportioned.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicable post‑judgment interest rate when a landlord obtains a money judgment in a breach‑of‑contract action on a residential lease that includes unpaid rent plus other expenses and is not itemized	§ 11‑107(b) controls; the judgment is a "money judgment for rent of residential premises," so 6% applies to the whole judgment	§ 11‑107(b) should not apply to breach‑of‑contract judgments or to non‑rent components; "rent" means periodic occupancy payments and the 6% exception was meant for possession/summary ejectment contexts; 10% under § 11‑107(a) governs	Court held § 11‑107(b) applies: 6% rate governs the entire money judgment when it arises from rent of residential premises, even if the judgment includes other lease‑related charges and is not apportioned.

Med. Mut. Liab. Ins. Soc’y of Md. v. Davis, 389 Md. 95 (2005) (defines purpose and accrual of post‑judgment interest)
Mayor & City Council of Balt. v. Kelso Corp., 294 Md. 267 (1982) (discusses rationale for raising default post‑judgment rate to compensate plaintiffs and deter delay)
Md. State Highway Admin. v. Kim, 353 Md. 313 (1999) (historical context for interest on judgments)
Bottini v. Dep’t of Fin., 450 Md. 177 (2016) (statutory‑construction principles)
Lockett v. Blue Ocean Bristol, LLC, 446 Md. 397 (2016) (interpretation of "rent" in landlord‑tenant statutes; narrow construction of exemptions to remedial statutes)
Arthur Treacher’s Fish & Chips of Fairfax, Inc. v. Chillum Terrace Ltd. P’ship, 272 Md. 720 (1974) (measure of damages for commercial lease breach where possession never occurred)
Circuit City Stores, Inc. v. Rockville Pike Joint Venture Ltd. P’ship, 376 Md. 331 (2003) (contract damages and reletting/mitigation issues in commercial lease context)
Lamone v. Schlakman, 451 Md. 468 (2017) (use of legislative history as confirmatory when statutory language is clear)